Little Manila Rising v. United States Environmental Protection Agency

Background

Little Manila Rising, Medical Advocates for Healthy Air, and the Sierra Club brought two claims under the Clean Air Act against the United States Environmental Protection Agency, Michael Regan, and Martha Guzman Aceves. The first claim alleged that the EPA failed to perform a required duty: determining by June 30, 2024, whether the San Joaquin Valley had met the applicable air-quality standard by its attainment deadline.

California requested a one-year extension of the San Joaquin Valley’s attainment deadline, and the EPA proposed to approve it. After the plaintiffs filed this case, the EPA issued a final rule approving the extension to December 31, 2024. The rule became effective on December 19, 2024, after the Ninth Circuit denied the plaintiffs’ request to stop it. The EPA’s resulting deadline to make the attainment determination became June 30, 2025. The Ninth Circuit’s review of the extension remained pending.

Motion to dismiss and motion to stay

The defendants moved to dismiss the first claim, arguing that the EPA’s new deadline had not arrived and that the claim was moot or depended on the validity of the extension, which the Ninth Circuit had authority to decide. The plaintiffs asked the court to stay the claim instead. They argued that the claim concerned the EPA’s failure to meet the earlier deadline and that the Ninth Circuit might invalidate the extension.

The court granted the motion to dismiss and dismissed the first claim without prejudice. It reasoned that the claim depended entirely on finding the extension invalid. Under the Clean Air Act, the Ninth Circuit—not the district court—had jurisdiction to review the relevant agency action. The district court therefore concluded that it lacked subject matter jurisdiction over the first claim. The court stated that if the Ninth Circuit invalidated the extension and the EPA still failed to make the required determination, the plaintiffs could bring a mandatory-duty claim at that time. The court denied the plaintiffs’ motion to stay.

Motion to intervene

The San Joaquin Valley Unified Air Pollution Control District moved to intervene as of right, but only regarding the first claim. It took no position on the remaining claim. Because the court dismissed the claim that supported the intervention motion, the court found that the District had not shown a significant protectable interest in the remaining claim. The court denied the motion to intervene without prejudice.

Disposition

The court denied the motion to stay, granted the defendants’ motion to dismiss, dismissed the plaintiffs’ first claim without prejudice, and denied the motion to intervene without prejudice. The court also reset the case-management conference from March 6, 2025, to March 11, 2025, and directed the parties to submit a joint case-management statement by March 4, 2025. The opinion states that the defendants did not seek dismissal of the plaintiffs’ second claim.